Extract from circular No. 108, dated 20-3-1973:
A transport contract cannot ordinarily be regarded as contract for carrying out any work and, as such, no deduction in respect of income-tax is required to be made from payments made under such a contract.
In the case of a composite contract involving transport as well as loading and unloading, the entire contract will be regarded as works contract and income-tax will have to be deducted from payments made thereunder.
Where, however, the element of labour provided for loading and unloading is negligible, no income-tax will be deductible.